Dormant account policy

1. Introduction, definitions and scope

1.1 This policy has been prepared to define the procedures for the treatment of inactive and dormant accounts.

1.2 Definition of dormant or inactive accounts: An account is considered dormant or inactive if there have been no transactions initiated by the account holder for a period of 12 (twelve) months. This includes savings accounts, current accounts and other types of bank deposits.

1.3 The term "inactive account" or "dormant account" refers to any trading account or depository client account in which no trades or debit transactions have been carried out in the last 12 (twelve) months across all exchanges.

1.4 This policy applies to all Rintral Trading Depository Participant client accounts.

2. Monitoring

2.1 The AML/KYC Compliance team monitors client accounts on a regular basis to identify any inactive or dormant accounts and to ensure compliance with the established policies.

2.2 The verification of inactive or dormant accounts in the system is carried out on a monthly basis, by the end of each calendar month, following the procedures described below.

3.1.1 Identification of inactive accounts

The AML/KYC Compliance team generates a list of all accounts that have shown no activity in the last 12 months.

3.1.2 Classification

The AML/KYC Compliance team classifies these accounts as inactive or dormant accounts and forwards the list to the Operations team for further action.

3.1.3 Deactivation

The Operations team deactivates the identified accounts in the system and updates the status of these client codes in the exchange database.

3.1.4 Settlement of accounts

Once an account has been identified as inactive, the client's funds and dormant account are settled in the presence of the AML/KYC Compliance team. The settlement process will follow the periodicity (monthly or quarterly) chosen by the client, and all assets (funds, securities or other collateral) shall be returned to the client. A statement detailing this settlement must be sent to the client.

3.1.5 Continued reporting

The Operations team continues to send all usual client reports for deactivated accounts.

3.2.1 Client request

If a client wishes to trade or transfer securities or funds from or to their account, and the account has been deactivated due to dormancy, the client must submit a formal request for reactivation through our customer support channels (by email or by creating a support ticket).

3.2.2 Verification

The AML/KYC Compliance team verifies the identity and credentials of the client. This includes:

• Confirming the client's identity using current KYC documentation.
• Verifying the client's request through a registered contact method, such as phone or email.

3.2.3 Documentation

The client must provide any updated KYC documents if required. The AML/KYC Compliance team shall ensure that all documentation is current and valid.

3.2.4 Approval

Once verification and documentation are complete, the AML/KYC Compliance team approves the reactivation request.

3.2.5 Reactivation process

The Operations team is responsible for:

• Reactivating the client's account in the system.
• Updating the client's status in the exchange database.
• Notifying the client of the reactivation by email or another agreed communication channel.

3.2.6 After reactivation

The client is informed that their account is now active and that they may proceed with trading or transferring securities or funds.

3.2.7 Record keeping

All requests, verifications and communications regarding the reactivation process are documented and retained for compliance and audit purposes.

3.3.1 Monthly inactive account fee

When an account becomes inactive, a monthly inactive account fee will be charged. This account maintenance and fund custody fee covers the upkeep of the account and the safekeeping of the funds deposited in it.

This fee will continue to be charged until the account is reactivated or the funds are insufficient to cover the fee.

3.3.2 Amount

If a user's trading account remains inactive for 12 consecutive months, the platform applies a monthly maintenance fee of 4 euros until activity resumes and the balance is reset. Following this, the account is temporarily suspended.

3.3.3 Notification

The fee charge will be duly notified to the client through the communication methods accepted by them.

3.3.4 Abandoned accounts

If there has been no deposit, withdrawal or other contact from you for 12 consecutive months, your account will be considered abandoned. In accordance with the law, funds from abandoned accounts will be reported and disbursed appropriately.

3.3.5 Account statements

Inactive accounts will receive only one annual statement.

3.4.1 Terms and conditions

This policy forms part of the terms and conditions that clients must accept when contracting products.

3.4.2 Client confirmation

For all existing clients, the update to the existing terms and conditions of the contract, including the changes introduced by this policy, is sent through the communication channel agreed with the client.

Once notified, and in accordance with Spanish Law 16/2009, clients will have a period of 2 (two) months to communicate their disagreement with this policy, which will result in the cancellation and closure of all their accounts.

This policy ensures the proper management of inactive accounts and compliance with legal requirements regarding abandoned funds.